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Home My WebLink About07-5793 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KAREN J VARVEL Defendant No : 41- 5143 Givi l Ter'4 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06136038 C A Pit WLG Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KAREN J VARVEL Defendant Civil Action No COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 I COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: KAREN J VARVEL 10 N MIDDLESEX RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002810374447 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of September 19, 2007 , in the amount of $4779.94 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , KAREN J VARVEL INDIVIDUALLY , in the amount of $4779.94 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys, fees of $500.00 , and costs. James rmbrodt,42524 WELT W INBERG & REIS CO., L.P.A. 436 S vent Avenue, Suite 2718 Pitt urg , PA 15219 (412 434 7955 FAX 41 338-7130 06 60 C A Pit WLG This law firm is a debt collector att i.ng to collect this debt for our client and any information obtain will be used for that purpose. $4,779.94 $588.00 CARD Payment Due Date July 12, 2007 13 SDSN6A01 0002659 KAREN VARVEL 10 N MIDDLESEX RD CARLISLE PA 17013-1627 EXHIBIT l Address, e-mail or telephone change? Print change ins ace above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Enter Amount Enclosed Below Please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of $679.94. Paperless Statements are a great way to keep track of your Discover@ Card activity, and allow you to control when and where you view your information. Visit Discovercard.com/ps PO BOX 15251 111nr11nn111111 WILMINGTON DE 19886-5251 000006011002810374447047799400000000058800 Discover More Card Account Summary Closing Date: June 13, 2007 page 1 of 1 Account Number 6011 0028 1037 4447 Previous Balance $4 587.64 Payment Due Date July 12, 2007 Payments And Credits , 0 00 Minimum Payment Due $588.00 Purchases . + 78 00 Credit Limit $4,100.00 Cash Advances . + 0 00 Credit Available $0.00 Balance Transfers . + 0 00 Cash Credit Limit $1,066.00 Finance Charges . + 1 14 30 Cash Credit Available $0.00 New Balance $4,779.94 You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cashback Bonus® Opening Cashback Bonus Balance $ 1.30 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 1.30 Cashback Bonus® Anniversary - _ Available to Redeem $ 0.00 Date: August 13 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card available. Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online of Discovercard.com TDD (Telecommunications Device for the Deaf): Customer Service: 1-800-DISCOVER (1-800.347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Other/Miscellaneous Jun 13 Jun 13 OVERLIMIT FEE $ 39.00 Jun 13 Jun 13 LATE FEE 39.00 Information For You * * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for future payments should be made immediately. Soon we'll no longer be printing your full account number on your statement. It's just another way to keep your in formation safe. But of course, if for any reason you need your full account number, it'll still be right there on your card. 'Finance Charge Summary Average Daily Dail P i d Nominal ANNUAL ANNUAL Periodic PERCENT Transaction Fee y er o ic Balances Rates AGE PERCENTAGE FINANCE RATES RATES CHARGES FINANCE CHARGES current billing period: 31 days Purchases $4642.71 0.07942% Cash Advances $0 28.99% F 28.99% $114.30 none 0.07942% 28.99% F 28.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary IV) as noted above. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsifications to authorities, that he/she is 724r)ez M ) Accounts Manager of DFS Services, LLC , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. 1&k)? tu ntov ture) 0 WWR # 6136038 KAREN J VARVEL 6011002810374447 O ?` v d f ?0 N u SHERIFF'S RETURN - REGULAR CASE NO: 2007-05793 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS VARVEL KAREN J MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the DEFENDANT , at 1320:00 HOURS, on the 8th day of October , 2007 at 10 N MIDDLESEX ROAD CARLISLE, PA 17013 by handing to KAREN VARVEL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 I i/o/ ),51 4 ?/ 32.80 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 10/09/2007 WELTMAN WEINBERG REIS By: Deput er:ff A. D. w 16 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KAREN J VARVEL Defendant No. 07-5793 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06136038 Judgment Amount $ 5279.94 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-5793 CIVIL TERM KAREN J VARVEL Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, KAREN J VARVEL above named, in the default of an Answer, in the amount of $5279.94 computed as follows: Amount claimed in Complaint $4779.94 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $5279.94 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. B Y• WILLIAM T. MOrAN, ESQUIRE PA I.D.#47437 vv Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06136038 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t` Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 10 N MIDDLESEX RD CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff KAREN J VARVEL De f enydant (s) IMPORTANT NOTICE TO: KAREN J VARVEL 10 N MIDDLESEX RD CARLISLE,PA 17013 Date of Notice: 12-(0 WWR#: 06136038 Case # 0- F))9 ')j CIVIL Te ON\ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: rU?vL-'F?? f.UCY??YWV?'""_ PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 d IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 07-5793 CIVIL TERM Plaintiff vs. KAREN J VARVEL Defendant NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affant further states that based upon investigation it is the affiant's belief that the Defendant, KAREN J VARVEL is not in the military service. Affant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, KAREN J VARVEL is not in the military service. Further Affant sayeth naught. l AFFI NT SWORN TO AND SUBSCRIBED in my presence this 30 day of J`} 0_. COII IO?t"a" ?^ 1:7 - CITF-I' W MAN A ^- NOT Y PUBLIC This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 NOV-26-2007 06:17:06 < Last Name First/Middle Begin Date TActive Duty Status Service/Agency VARVEL KAREN Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 14. 41aut lot A?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http_//www.defense_.link.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/26/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BSOLITKL WQG https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/26/2007 7IO ( -6A- c-3 _ U -TI r° H, I oo 00 (fi ? c.3 i CO ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-5793 CIVIL TERM KAREN J VARVEL Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on (xx) Assumpsit Judgment in the amount of $5279.94 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary PRO NOTARY (OR DEPUTY KAREN J VARVEL 10 N MIDDLESEX RD CARLISLE,PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KAREN J VARVEL Defendant SOVEREIGN BANK, Garnishee, No. 07-5793-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6136038 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-5793-CIVIL TERM KAREN J VARVEL Defendant SOVEREIGN BANK, Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KAREN J VARVEL, Defendant 3. against SOVEREIGN BANK, Garnishee 4. Judgment Amount $ 5,279.94 Interest $ 463.48 Costs $ SUBTOTAL: $ 5,743.42 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6136038 MOr? v''.,° a J F'.k 1 r1 i .v...: #xl/ !o #,3 pia bit ea s0 6& c L- Y-* 0 g1ltld 4? # Jars X-/ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5793 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KAREN J. VARVEL, 10 N MIDDLESEX ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SOVEREIGN BANK, 798 EAST SIMPSON STREET, MECHANICSBURG, PA 17055 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,279.94 Interest $463.48 Atty's Comm % Atty Paid $: w ?U Plaintiff Paid L.L. $.50 Due Prothy $ 2.00 Other Costs Date: 06/16/2009 (Seal) ?II ?.lA?G9 ?• C-G?A Curtis Long, Prothonotary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQ. Address: WELTMAN, WEINBERG & REIS, CO, L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 Sheriffs Office of Cumberland County R Thomas Kline k)i L..Wa,., - --FF Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy ??' Civil Process Sergeant Discover Bank Case Number vs. 2007-5793 Karen J Varvel SHERIFF'S RETURN OF SERVICE 06/25/2009 09:59 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 29, 2009, at 1000 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Karen Varvel, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W. High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, Customer Service Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 29, 2009 to Karen J. Varvel at 10 N Middlesex Road, Carlisle, PA 17013. 2007-5793 Discover Bank vs Karen J. Varvel So Answers, R. omas Kline, heriff By 2y Sheriff C? O C- p -n -- ' t HIM t J W ,. C=) L J j S ti ? 4 co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-5793 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE KAREN J VARVEL SOVEREIGN BANK ONLY Defendant SOVEREIGN BANK Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6136038 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KAREN J VARVEL Defendant SOVEREIGN BANK Garnishee Civil Action No. 07-5793 CIVIL TERM PRA.ECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE SOVEREIGN BANK ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, SOVEREIGN BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: 4?4 Sworn to and subscribed Before me the Day of JULY , 2009 RY PUB WILLIAM T. MOLCZA ESQUIRE PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6136038 FUF,&-&FICF OF 7HE PPa' 7-por?)T 2009 JUL 20 PM 2.4 6 +g. CO Pp M-rl of aria 1 q 0 l R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Discover Bank vs. Karen J Varvel S Office of Cumberland County F Irl f of Cumbr t , ? ? 20B AUG -5 F11 z w4 J 4FFM OF TM &tiEPkIFF (C iW Case Number 2007-5793 SHERIFF'S RETURN OF SERVICE 06/25/2009 09:59 AM - Mark Conklin, Dept 2009, at 1000 hours, attached of the within named defendant, named garnishee, Sovereign E 17013, by handing to Julie Mye together with three true and aft to her. Sheriff, who being duly sworn according to law, states that on June 29, herein commanded all goods, chattels, rights, debts, credits, and monies wit: Karen Varvel, in the hands, possession, or control of the within ik, 17 W. High Street, Carlisle, Cumberland County, Pennsylvania Customer Service Manager, personally three copies of interrogatories ed copies of the writ of execution and made the contents there of known The writ of execution and notice to defendant was mailed on June 29, 2009 to Karen J. Varvel at 10 N Middlesex Road, Carlisle, PA 17013. 08/06/2009 R. Thomas Kline Sheriff, who being duly sworn according to law, states this writ is returned SATISFIED. SHERIFF COST: $186.00 (PA D BY DEFENDANT) SO ANSWERS, ?/ 2/6 /of August 06, 2009 b Z d Z Z k n.r bOOZ R1 OM AS KLINE, SHE IFF B S aron R. Lan (;- 7/l'r? PC". 2 "'p 9b15 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-5793 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KAREN J. VARVEL,10 N MIDDLESEX ROAD, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SOVEREIGN BANK, 798 EAST SIMPSON STREET, MECHANICSBURG, PA 17055 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $5,279.94 Interest $463.48 Atty's Comm % AttyPaid $J I q .5'Q Plaintiff Paid Date: 06/16/2009 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQ. L.L. $.50 Due Prothy $ 2.00 Other Costs /_// &?J ,C ;??f Curtis R. Long, Prothonotary By: Deputy Address: WELTMAN, WEINBERG & REIS, CO, L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF J ', Telephone: 412-434-7955 Supreme Court ID No. 47437 DISTRIBUTION PLAINTIFF WRIT NO. Discover Bank -vs- Karen J. Vravel Real Debt Interest Attorney's Comm. Writ Costs, Atty Writ Costs, Pltff. Miscellaneous Attorneys Fees $ 5,279.94 463.48 119.50 $ 5,862.92 Sheriff's Costs: Docketing $ 18.00 Poundage 101.10 Law Library .50 Prothonotary 2.00 Service 5.40 Postage Advertising Postpone Sale Bad Check Charge Surcharge 30.00 Garnishee 9.00 Levy 20.00 TOTAL $ 186.00 Defendant Paid to Sheriff Advance Costs Total Collected DISTRIBUTION Pd. To Pltff. $ Refund of Adv. Costs Sheriff's Costs 5,862.92 150.00 186.00 $ 6,048.92 150.00 $ 6,198.92 So Answers: R. Thomas Kline, Sheriff B Discover Bank 2007-5793 I If- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KAREN J VARVEL Defendant(s) No. 07-5793 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. # 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR#6136038 DIS t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-5793 CIVIL TERM KAREN J VARVEL Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W? PA I.D. # 42 WELTMA 1400 Kop el 436 Seve th (412) Sworn to and subscribed before me this 1y day of October, 09 ARY ,/PA 7999 WWR #6136038 COMMONWEALTH OF PENNgYLVANIA Notarial 8001 Wayne A. Jones. Notary Public City of Pittsburgh, Allegheny County rdey .cmmission Expij?es June 29. 2010 Mennbe,Pennsyluaria Association of Notaries Esquire & REIS CO., L.P.A. venue 15219 F7L D-Ci =sU" OF THE PP TP-- ')NOTARY 2009 NOY -2 Phi 3: 39 r? tit p+1 6, i ?, 4%. oo P D ?? Cr'o 4319043 e as& 7